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Hi All,

 

This is important!

 

 

Some of you know this, but I don't think the majority do. You must log in the aircraft logbook all SB's pertaining to your SLSA plane whether they apply and when they were done or whether they don't apply they still should be logged and addressed. The owner can do this and a good place to make a list is in the back of your logbook. This is supposed to be done before you can sell and should be done by the seller if your are the buyer. It's easy to do so it should be easy to get'er done. Here is a document below and the corresponding FAR that was put in effect March 2010.

FAR REG.pdf

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I'd like some clarification of the statement above.

 

1. I'm trying to understand the rule. Is the requirement to log SB found in 91.327(2) a (7) which refers to 43.9? Or is it in some other paragraph?

 

2. Above you talk about an SB that pertains to your airplane but doesn't apply and say this still needs to be logged. I don't understand. How does something "pertain" but not "apply"? Can you give me an example?

 

3. I did not see anything in the FAR that said I had to log an SB that I did not have to perform on my airplane. It seems to me the FAA wants us to log all work we do. The FAA does not tell us we have to log work we don't have to do. I didn't see anything in the FAR that said that double checking an SB to see if I had to perform some action was by and of itself a loggable item.

 

I am not talking here about whether it is a good management tool to list all SB and say which require action on my airplane and which don't - I am only talking about what the FAR REQUIRES I do. The language is puzzling and I want to be sure.

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Jim, here's my log page which was required per FD direction in their SA-ASTM-CTSW-04. This is an example of a SB that doesn't apply to my airplane but that requires a log entry to show that I have complied with it. I also list this SA and show the disposition of it in a separate list I maintain of SB's and SA's that are published by FD, Rotax, Avionics manufacturers and propellor manufacturer.

aircraft log 11.23.pdf

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Dick,

 

Thanks. Yes, I know there are mandatory entries even if no work needs to be done. But not all entries are that way. You comment points out that that I should have been more clear. I'm only talking about SB where were are not explicitly required to make an entry if it does not apply to us. Thanks for clarifying that.

 

 

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OK Jim. Got the distinction you are making. Re-reading Roger's post, he does seem to indicate that a log entry must be made in one's log book of all SB's, whether these might be applicable to one's aircraft or not. FWIW, I do not make a log entry but I do maintain a SB "status list" which is kept in my records and it is updated each time a new SB is issued. On it, every SB that is issued which pertains to my CTSW, whether it applies to my airplane or not, is shown. The disposition of each SB is accounted for on this list. A similar list is kept for Rotax, avionics and Neuform propellor.

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If you have a 2006 CTSW keep a log of each SB that pertains to CTSW's. List them in the back of your logbook. Write next to each one that you have complied and the date that it was done or that that SB doesn't apply to your plane. It could just be a serial number issue within the CTSW planes.. Forget CTLS entries.

The CTLS people need to log bulletins that pertain to LS's. Yes there are some that pertain to both (i.e.an engine SB).

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I am not a lawyer and this is not legal advice.

 

Current as of Jan. 2012. This is an FD publication that was posted. Questions may be better answered through them.

 

http://ecfr.gpoacces...0.1.3.10.4.7.14

 

Did you look at the FAR? I did. The last time it was changed was in 2004. You, not FD, said it was "was put in effect March 2010". Did FAR 91.327 change in 2010 or not?

 

I'll tell you what probably happened. FD probably found out that they were not in compliance with the ASTM regarding documentation of SB's. So they asked owners to get them up to date. No problem with that. I filled out the form they sent. But I don't believe this is an FAR issue. Unless you or someone else can prove otherwise.

 

I have no problem with the posting of notices from FD. I don't like questionable opinions stated as fact concerning our legal obligations.

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If you have a 2006 CTSW keep a log of each SB that pertains to CTSW's. List them in the back of your logbook. Write next to each one that you have complied and the date that it was done or that that SB doesn't apply to your plane. It could just be a serial number issue within the CTSW planes.. Forget CTLS entries.

The CTLS people need to log bulletins that pertain to LS's. Yes there are some that pertain to both (i.e.an engine SB).

Your restating the position but not answering my question in my first post above which is to cite the reference that requires it. The actual wording by either FD or FAA, now somebody's interpretation.

 

 

 

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Hi All,

 

This is important!

 

 

Some of you know this, but I don't think the majority do. You must log in the aircraft logbook all SB's pertaining to your SLSA plane whether they apply and when they were done or whether they don't apply they still must be logged and addressed. The owner can do this and a good place to make a list is in the back of your logbook. This is supposed to be done before you can sell and should be done by the seller if your are the buyer. It's easy to do so it should be easy to get'er done. Here is a document below and the corresponding FAR that was put in effect March 2010.

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Hi All,

 

This isn't hard to find it's all over the web especially back in 2010 and if you know how to search. Call the FAA in OK and they will tell you the same thing.

 

 

Read half way down: "Added that LSA Safety Directives need to be saved and complied with which was missing from the original rule. §91.417 Maintenance records."

http://beasportpilot...faa-rules-2010/

 

 

Read #20: " 20. Require aircraft owners or operators to retain a record of the current status of applicable safety directives for special light-sport aircraft."

 

http://edocket.acces...0/2010-2056.htm

 

 

This was all part a a big change in several rules back then. This was posted back even before it became a reg.

 

Bottom line if you have a CTSW log the directives for the CTSW and state that you complied or your serial number was not included. If you have a CTLS then log the CTLS directives.

If the SB or SD, or whatever, is for a CTSW and you own a CTSW, but you are exempt because of your serial number the SB or SD still pertains to your CTSW and you need to show you are not included only by that serial #.

 

Like the saying goes, Pay now (spend 20 min making sure your SA, SD, SB SI are logged) or pay later.

An ounce of prevention is worth a pound of cure especially when it comes time to sell.

 

 

For some reason keeping well documented records seems to be the hardest thing to get mechanics and owners to do? People seem to resist good documentation right to the grave.

I don't understand what the reluctance is here. It's free, it takes 20 minutes, it's in writing, it's easy and it's the the right thing to do.

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Here is more,

 

Just got off the phone with Edsel Ford the head of the LSA section in OK.

He said the same thing as I have posted here. Refer to my last post for the documentation in the logbook. this has been this way since April 2010.

 

 

Here is the Far 91.417

http://www.risingup.com/fars/info/part91-417-FAR.shtml

 

Pay special attention to section V and B-2

 

It is mandatory to have and transfer these records in writing at the time of sell or if you are the buyer you need to require these documents or it can not be sold.

 

 

This should be enough documentation to get everyone moving in the right direction.

 

It's the black furry guy's job to help keep us informed.ph34r.giflaugh.gif

You gotta love those happy camper types.rolleyes.gif

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Having read these, the rule applies just to Service Directives and just says documentation must be saved and also passed on when transferring the plane. It doesn't have to be the logbook, but that is surely the best place. Just to muddy the water a bit more, I was confused chasing down compliance on my bird since FD now refers to things by the ASTM standard and calls them Service Alerts. So I have entries in my log for SD 14 but that is now referred to as SA-02

http://documents.flightdesignusa.com/Service-Notice%20Format.pdf

Ironically, the FAA rulemaking doesn't mention compliance with service alerts so technically you can now legally ignore them WRT this documentation trail.

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Here is more,

 

Just got off the phone with Edsel Ford the head of the LSA section in OK.

He said the same thing as I have posted here. Refer to my last post for the documentation in the logbook. this has been this way since April 2010.

 

 

Here is the Far 91.417

http://www.risingup.com/fars/info/part91-417-FAR.shtml

 

Pay special attention to section V and B-2

 

It is mandatory to have and transfer these records in writing at the time of sell or if you are the buyer you need to require these documents or it can not be sold.

 

 

This should be enough documentation to get everyone moving in the right direction.

 

It's the black furry guy's job to help keep us informed.ph34r.giflaugh.gif

You gotta love those happy camper types.rolleyes.gif

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A safety directive and a service bulletin (or alert bulletin, service letter, or whatever the manufacturer is calling it) is NOT the same thing. FAR 91.417 requires the owner to keep records for applicable safety directives only. Non-applicable stuff is not required to be documented as has been posted.

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Hi Kurt,

 

Your ELSA is not included. Your right it doesn't have to be the logbook, just documented paperwork that has to be passed on to the buyer or presented if an FAA rep. wants to see it for any reason. The language is clear enough and the FAA and FD have made their positions known. The discussion this morning included AD, SB, SA and SI's. An owner is not in a position to defy that unless they are in a position to take the heat later and not cry foul because they think it didn't apply to them. I think I'll spend my 15 min. and make sure mine are documented. If you don't do it then it is seller beware and buyer too. As an inspector I would advise a client to require this paperwork from the seller or not buy it since it can be deemed illegal and have possible consequences to both. I would put my buy money in an escrow account and make sure that paperwork is there to protect yourself. I have had too many used CT's come into the shop and the second owner has no idea what was done because of lousy paperwork. It's for your own protection.

 

Hi Doug,

 

The FAA says they are the same in the SLSA world and if it requires attention then it needs to be documented. Forget the GA language and rules they don't apply. SLSA is a class unto itself for regs.

 

 

The info here on the forum is designed and presented to help all in making the flights safe and fun, to offer maint help and trouble shooting, education, keeping out the harms way with the legal and FAA side of things and for this dog the camaraderie.

However you choose to use that information is up to each individual.

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I don't have to, but I am current with all of these including one I didn't have to get, according to FD. So I'm not trying to defy FD or the FAA or encourage any sort of method to work around these. My point was only that FD has made an error in calling them SA's since that breaks with the FAR language, and thus they have some unintended liablity. If I were SLSA, then I could legally get away without documenting an SA compliance. I could sell it to an unsuspecting buyer whose A&P didn't know to look for SA's since he was hunting just for Service directives. If the plane then crashed, FD would have some responsibility for calling it the wrong thing.

 

Legal language is very specific for a reason. I don't mean to encourage any sort of flame war here and do suggest everyone, ELSA or not, log compliance as it is only prudent.

 

Cheers all,

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Hi Kurt,

 

Your ELSA is not included. Your right it doesn't have to be the logbook, just documented paperwork that has to be passed on to the buyer or presented if an FAA rep. wants to see it for any reason. The language is clear enough and the FAA and FD have made their positions known. The discussion this morning included AD, SB, SA and SI's. An owner is not in a position to defy that unless they are in a position to take the heat later and not cry foul because they think it didn't apply to them. I think I'll spend my 15 min. and make sure mine are documented. If you don't do it then it is seller beware and buyer too. As an inspector I would advise a client to require this paperwork from the seller or not buy it since it can be deemed illegal and have possible consequences to both. I would put my buy money in an escrow account and make sure that paperwork is there to protect yourself. I have had too many used CT's come into the shop and the second owner has no idea what was done because of lousy paperwork. It's for your own protection.

 

Hi Doug,

 

The FAA says they are the same in the SLSA world and if it requires attention then it needs to be documented. Forget the GA language and rules they don't apply. SLSA is a class unto itself for regs.

 

 

The info here on the forum is designed and presented to help all in making the flights safe and fun, to offer maint help and trouble shooting, education, keeping out the harms way with the legal and FAA side of things and for this dog the camaraderie.

However you choose to use that information is up to each individual.

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If I am understanding you to say that manufacturer's service information (SB'S, Alerts, Service Letters, etc.......) are legally the same as Safety Directives, please provide regulatory support for this statement. If I have misunderstood what you are saying, I appologize.

 

If I understood you correctly that the status of NON-applicable Service Directives, and/or SB's etc..... are required to be kept on record, please provide regulatory support for this statement. If I misunderstood what you are saying, I appologize.

 

It is true that Safety Directives are unique to SLSA. The rules for performance of maintenance on SLSA are found in part 43. The owner must maintain/transfer records for that maintenance as required by part 91.417. I don't read anything in these rules that say that manufacturer's service information is the same as a safety directive, or that non-applicable stuff must be documented.

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I'd like some clarification of the statement above.

 

1. I'm trying to understand the rule. Is the requirement to log SB found in 91.327(2) a (7) which refers to 43.9? Or is it in some other paragraph?

 

2. Above you talk about an SB that pertains to your airplane but doesn't apply and say this still needs to be logged. I don't understand. How does something "pertain" but not "apply"? Can you give me an example?

 

3. I did not see anything in the FAR that said I had to log an SB that I did not have to perform on my airplane. It seems to me the FAA wants us to log all work we do. The FAA does not tell us we have to log work we don't have to do. I didn't see anything in the FAR that said that double checking an SB to see if I had to perform some action was by and of itself a loggable item.

 

I am not talking here about whether it is a good management tool to list all SB and say which require action on my airplane and which don't - I am only talking about what the FAR REQUIRES I do. The language is puzzling and I want to be sure.

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You are correct. There is no regulatory requirement to document non-applicable service info, or Safety Directives. Some times a document will largely apply to a specific model of machine, and further define the applicability to certain serial numbers. This information may show up in a maintenance entry as "Service Bulletin ....... not applicable by aircraft serial number", or "Safety Directive number ...... effective date of ....... not applicable due to subject part not installed". In both of these cases, it shows due diligence on the part of the owner/maintenance provider in that research was done to verify the non-applicablilty, however, legally speaking, this information does not have to be included in required maintenance records ref. FAR 91.417.

You are also correct in that the person performing maintenance must make a record entry of the maintenance that was performed (not maintenance that was not performed). I have paraphrased part FAR part 43.9. This does not include required inspection entries, as they are covered by other regs.

 

Doug Hereford

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[ (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the

next action is required.]

 

If the SB applies to my airplane, I will comply and log it. If FD says specifically that a given SB must be logged as having been accomplished even though my airplane does not require action, I will log it. If the SB does not apply to my airplane and I am not required to log that fact, I will not log it.

 

In my opinion, what we are seeing is people misinterpreting the reg and then foisting their opinion off as fact. In other words, each of us should carefully review the primary documents and make our own decision. Since we are all individually responsible, we should each satisfy ourselves that we are in compliance. Some people talk to priests, some people talk directly to god. To each his own.

 

 

 

 

 

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